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Implementing Procedures for the

NIOSH Policy on the Appearance of Bias for the EEOICPA Program &

General Conflict of Interest Requirements

I. Introduction

The purpose of this document, which replaces the NIOSH Statement of Policy: Management of 

Conflict or Bias in the Radiation Dose Reconstruction Program, Rev. 2 (June 24, 2009) (COB Policy), is 

to provide NIOSH management and staff (classified as regular Government employees), the Advisory 

Board on Radiation and Worker Health (Advisory Board or Board) (classified as special Government 

employees, or “SGEs”), and HHS contractors and subcontractors (here termed Program Contractors) 

providing technical and other services to NIOSH and HHS in support of the EEOICPA program, with 

procedural guidance in carrying out their respective responsibilities under the NIOSH Policy on the 

Appearance of Bias for the EEOICPA Program & General Conflict of Interest Requirements (2010) 

(AOB Policy).

As set forth below, these procedures provide a step-by-step roadmap for handling conflict-ofinterest and bias issues in a manner consistent with the NIOSH AOB Policy.

The first section describes reporting requirements – what type of information needs to be reported, 

who needs to submit a report, and to whom those reports should be submitted. The next section 

discusses review of the reported information, focusing on which persons have the responsibility to 

review those reports.

Following the subject of review, the procedures next address determinations and remedies. For 

determinations, the procedures set forth what the reviewing parties must determine to decide if a 

conflict or bias exists. If either is found to be present, the remedies section of the procedures 

describes what remedies may be available to permit an otherwise conflicted individual to participate 

in a particular matter; who may submit a request for a remedy; and what information the request 

should contain. The procedures then detail the criteria that will be used to determine if a requested 

remedy should be granted, as well as who has the power to grant such requests, and the conditions 

inherent in granting such requests.

The next section of the procedures lists both key Program functions (for example, dose 

reconstructor, SEC reviewer, document owner and site expert) and Program support functions (for 

example, multiple-site technical information bulletin owner and subject expert) and which functions 

may be performed by conflicted individuals under what circumstances (a more complete description 

of these functions is located in Appendix A to the procedures).

Finally, the procedures describe methods of publicly declaring, via both the Internet and at public 

meetings, individuals’ reported conflicts and biases that have been determined to exist, as well as 

any remedies issued to such persons.

Within each of the main categories listed above are subcategories that separately address the 

requirements as they apply to NIOSH, the Advisory Board, and Program Contractors. These 

requirements are found in statute (18 U.S.C. § 208, which addresses financial conflicts of interest) 

and regulation (5 C.F.R. § 2635.502, which is issued by the U.S. Office of Government Ethics (OGE) 

and addresses the appearance of loss of impartiality), in addition to the NIOSH AOB Policy (which 
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addresses appearance of bias). (Both 18 U.S.C. § 208 and 5 C.F.R. § 2635.502 are also contained in 

an Appendix to these procedures.) Nothing in these procedures should be read in any way to 

change or lessen the requirements outlined in the pertinent statute and regulations.

II. Reporting Matters of Potential Financial Conflict of Interest, Potential Appearance of Loss of 

Impartiality, and Appearance of Bias

This section explains what information needs to be reported, who needs to make such reports, and to 

whom the reports should be made.

A. Entities Required to Report

1. NIOSH management and staff involved in the EEOICPA program (including but not limited to 

those employees in the NIOSH Division of Compensation Analysis and Support (DCAS)).

2. Members of the Advisory Board on Radiation and Worker Health.

3. All Program Contractors (both companies and individuals) providing services to NIOSH 

and/or the Advisory Board in support of the EEOICPA program.

B. Information Required to be Reported

The following information is required to be reported by all individuals and companies falling 

under section II.A above:

1. Potential and Actual Financial Conflicts of Interest (governed by 18 U.S.C. § 208 for 

employees (including SGEs), and governed by the conflict-of-interest requirements of the 

Federal Acquisition Regulation (FAR) and those conflict-of-interest requirements 

incorporated into the contracts with CDC by the agency for contractors).

2. Potential Appearances of Loss of Impartiality (governed by OGE regulation 5 C.F.R. § 

2635.502 for employees (including SGEs), and governed by the conflict-of-interest 

requirements of the Federal Acquisition Regulation (FAR) and those conflict-of-interest 

requirements incorporated into the contracts with CDC by the agency for contractors).

3. Potential Appearances of Bias (governed by the NIOSH AOB Policy).

C. Recipients of Reported Information

The information required to be reported under section II.B above is to be provided as follows:

1. NIOSH Employees

A. Financial Conflicts of Interest

NIOSH employees must report any financial holdings, interests and outside affiliations to 

the NIOSH Appearance of Bias/Conflict or Bias (AOB/COB) Officer1

 or the CDC Ethics 

Officer2

, or another NIOSH-designated individual, in writing, using the NIOSH conflict-ofinterest disclosure form (attached as an Appendix to this document) provided for this 

purpose, and (for those NIOSH employees required to so file) the OGE Form 450, 

 1 Currently, the NIOSH AOB/COB Officer is Frank Hearl, NIOSH Chief of Staff.

2 Currently, the CDC Ethics Officer is Teresa Walker-Mason.
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“Confidential Financial Disclosure Report,” which is filed with and reviewed by the CDC 

Ethics Office. If no form is available, the report should be made via either email or 

hardcopy. All such reports must be reviewed to determine what if any potential or 

actual conflicts exist.

B. Potential Appearance of Loss of Impartiality

NIOSH employees must report any potential appearances of loss of impartiality to the 

NIOSH AOB/COB Officer or the CDC Ethics Officer, or another NIOSH-designated 

individual, in writing, using the NIOSH conflict-of-interest disclosure form provided for 

this purpose. If no form is available, the report should be made via either email or 

hardcopy. All such reports must be reviewed to determine what if any potential or 

actual conflicts exist.

C. Potential Appearance of Bias

NIOSH employees must report any potential appearances of bias to the NIOSH AOB/COB 

Officer, or another NIOSH-designated individual, in writing, using the NIOSH conflict-ofinterest disclosure form provided for this purpose. If no form is available, the report 

should be made via either email or hardcopy. All such reports must be reviewed to 

determine what if any potential or actual conflicts exist.

2. Advisory Board

A. Financial Conflicts of Interest

Advisory Board members must report any financial holdings, interests and outside 

affiliations by submitting the OGE Form 450, “Confidential Financial Disclosure Report,” 

and a copy of their curriculum vitae to the CDC Committee Management Office (CMO) 

or otherwise via email or hardcopy to the Designated Federal Official (DFO) for the 

Advisory Board, and by discussing potential conflicts with both these persons and 

attorneys in the Public Health (specifically, the Radiation Compensation Legal Team 

(RCLT)) and Ethics Divisions of OGC.

3 All such reports must be reviewed to determine 

what if any potential or actual conflicts exist.

B. Potential Appearance of Loss of Impartiality

Advisory Board members must report4 any potential appearances of loss of impartiality 

to the DFO in writing, via either email or hardcopy, referencing the information 

described above in section II.C.2.A as needed. All such reports must be reviewed to 

determine what if any potential or actual conflicts exist.

C. Potential Appearance of Bias

Advisory Board members must report5 any potential appearances of bias to the DFO in 

writing, via either email or hardcopy, in the manner described above in section II.C.2.A.

All such reports must be reviewed to determine what if any potential or actual conflicts 

exist.

 3 Currently, the Designated Federal Official for the Advisory Board is Ted Katz. 4 This does not include appearances of loss of impartiality for which guidance has already been provided to the 

Board member by the DFO and/or CMO.

5 This does not include appearances of bias for which guidance has already been provided to the Board member by 

the DFO and/or CMO.
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3. Program Contractors

A. Financial Conflicts of Interest

Program Contractors must report any financial holdings, interests and outside 

affiliations to their company’s official designated to receive such reports, using the form 

created or adopted by the company for this purpose. In turn, that official must report 

any potential or actual conflict(s) in question to the contract officer’s technical 

representative (COTR)6 with whom the company is engaged under its contract with the 

agency. If no form is available, the report shall be made in writing, via either email or 

hardcopy. All reports must be reviewed to determine what if any potential or actual 

conflicts exist.

B. Potential Appearance of Loss of Impartiality

Program Contractors must report any potential appearances of loss of impartiality to 

their company’s official designated to receive such reports, using the form created or 

adopted by the company for this purpose. In turn, that official must report the matter in 

question to the contract officer’s technical representative with whom the company is 

engaged under its contract with the agency. If no form is available, the report shall be 

made in writing, via either email or hardcopy. All reports must be reviewed to 

determine what if any potential or actual conflicts exist.

C. Potential Appearance of Bias

Program Contractors must report any potential appearances of bias to their company’s 

official designated to receive such reports, using the form created or adopted by the 

company for this purpose. In turn, that official must report the matter in question to the 

contract officer’s technical representative with whom the company is engaged under its 

contract with the agency. If no form is available, the report shall be made in writing, via 

either email or hardcopy. All reports must be reviewed to determine what if any 

potential or actual conflicts exist.

III. Review of Reported Information

This section explains which individuals are to review the reports discussed above, and on what type of 

matters the reviewers should focus.

1. NIOSH Employees

A. Financial Conflicts of Interest

All reports will be reviewed for potential or actual financial conflicts of interest by the 

CDC Ethics Officer, with potential input from the NIOSH AOB/COB Officer and other 

NIOSH and HHS officials, including the DCAS Director, as deemed necessary by the 

reviewing official. 

 6 Currently, the pertinent HHS contract officer technical representatives are Grady Calhoun (for ORAU); Ted Katz 

(for SC&A); J.J. Johnson (for ATL International); Jim Neton (for SENES and NCRP); and, for SRA, Leroy Turner (for 

Task Order 226), Chris Ellison (for TO 227), Dave Allen (for TO 228) and Lavon Rutherford (for TO 229). Should s/he 

deem it necessary to avoid potential or actual improper supervisory influence or other similar concerns, the NIOSH 

Director may assign a designee to fulfill some or all of the duties of a COTR as those duties are specified in these 

procedures.
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B. Potential Appearance of Loss of Impartiality

All reports will be reviewed for potential appearances of loss of impartiality by the CDC 

Ethics Officer or the NIOSH AOB/COB Officer, or other NIOSH-designated official, in 

consultation with the reporting individual and other HHS officials as deemed necessary 

by the reviewing official.

C. Potential Appearance of Bias

All reports will be reviewed for potential appearances of bias by the NIOSH AOB/COB 

Officer, or other NIOSH-designated official, in consultation with the reporting individual 

and other HHS officials as deemed necessary by the reviewing official.

2. Advisory Board

A. Financial Conflicts of Interest

All reports will be reviewed for potential or actual financial conflicts of interest by the 

DFO, in consultation with OGC attorneys in the Ethics Division and on the Radiation 

Compensation Legal Team within the Public Health Division, CDC Management Analysis 

and Services Office (MASO) staff and the affected Board member.

B. Potential Appearance of Loss of Impartiality

All reports will be reviewed for potential appearances of loss of impartiality by the DFO, 

in consultation with OGC attorneys in the Ethics Division and on the Radiation 

Compensation Legal Team within the Public Health Division, CDC MASO staff and the 

affected Board member.

C. Potential Appearance of Bias

All reports will be reviewed for potential appearances of bias by the DFO, in consultation 

with OGC attorneys in the Ethics Division and on the Radiation Compensation Legal 

Team within the Public Health Division, CDC MASO staff and the affected Board 

member.

3. Program Contractors

A. Financial Conflicts of Interest

All reports will be reviewed for potential or actual financial conflicts of interest by the 

contracting company’s project manager7

, or other contractor designee, in consultation 

with the contract officer’s technical representative8

, the agency contract officer9, and 

agency and HHS officials (including the NIOSH AOB/COB Officer). 

B. Potential Appearance of Loss of Impartiality

All reports will be reviewed for potential appearances of loss of impartiality by the 

contracting company’s project manager, or other contractor designee, in consultation 

 7 Currently, these individuals are Kate Kimpan (for ORAU), John Mauro (for SC&A), Thomas S. Tenforde (for NCRP), 

Vern McDougal (for ATL International), Warren Hoffman (for SENES), and Wendy Wise (for SRA).

8 As noted above, currently these individuals are Grady Calhoun (for ORAU); Ted Katz (for SC&A); J.J. Johnson (for 

ATL International); Jim Neton (for SENES and NCRP); and, for SRA, Leroy Turner (for TO 226), Chris Ellison (for TO 

227), Dave Allen (for TO 228) and Lavon Rutherford (for TO 229).

9 Currently, these individuals are Flo Black (for ORAU), Ruben Cruz (for SC&A), Dwight Favors (for ATL 

International), Flo Black (for SENES), Dwight Favors (for NCRP) and John Carolan (for SRA).
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with the contract officer’s technical representative, the agency contract officer, and 

agency and HHS officials (including the NIOSH AOB/COB Officer). 

C. Potential Appearance of Bias

All reports will be reviewed for potential appearances of bias by the contracting 

company’s project manager, or other contractor designee, in consultation with the 

contract officer’s technical representative, the agency contract officer, and agency and 

HHS officials (including the NIOSH AOB/COB Officer).

IV. Determinations and Remedies

A. Determinations

This section describes what the reviewing parties must determine to find that a conflict or bias 

exists.

1. NIOSH Employees

A. Financial Conflicts of Interest

In examining potential or actual financial conflicts of interest, the reviewing parties must 

determine if the NIOSH employee has a disqualifying financial interest and whether that 

financial interest is likely to be affected by the outcome of a particular matter with 

regard to a specific party, such as a Department of Energy (DOE) or Atomic Weapons 

Employer (AWE) facility, such that s/he should be prohibited from participating 

personally and substantially in an official capacity in that particular matter concerning 

that party.

B. Potential Appearance of Loss of Impartiality

With regard to a potential appearance of loss of impartiality, the reviewing parties must 

determine if a particular matter involving specific parties is likely to have a direct and 

predictable effect on the financial interest of a member of the NIOSH employee’s 

household, or if the NIOSH employee has a covered relationship10 with a specific person 

or entity who is a party (or represents a party) to a particular matter, such that the 

employee’s participation in his/her official capacity in that matter would cause a 

reasonable person with knowledge of the relevant facts to question the employee’s 

impartiality, and that the NIOSH employee should therefore be prohibited from 

participating in his/her official capacity in a particular matter involving specific parties.

C. Potential Appearance of Bias

With regard to a potential appearance of bias, the reviewing parties must determine 

whether the potential appearance of bias could raise questions as to the integrity of the 

 10 An NIOSH employee or Board member is deemed to have a covered relationship with: anyone with whom the 

employee has or seeks a business or financial relationship (other than a routine consumer transaction); a member 

of the employee’s household; a relative with whom the employee has a close personal relationship; anyone with 

whom the employee’s spouse, parent, or dependent child is serving or seeking to serve as an officer, director, 

trustee, general partner, agent, attorney, consultant, contractor, or employee; any person with whom the 

employee has served as an officer, director, trustee, general partner, agent, attorney, consultant, contractor, or 

employee within the past year; and any organization in which the employee is an active participant. See 5 C.F.R. § 

2635.502(b)(1).
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EEOICPA program and if the NIOSH employee should therefore be prohibited from 

participating in his/her official capacity in a particular matter involving specific parties. 

(A list of many, albeit not all, circumstances that could lead to a potential appearance of 

bias for federal employees or contractors may be found in the NIOSH AOB Policy, which 

has also been reprinted in an appendix to these procedures.)

2. Advisory Board

A. Financial Conflicts of Interest

In examining potential or actual financial conflicts of interest, the reviewing parties must 

determine if the Advisory Board member has a disqualifying financial interest and 

whether that financial interest is likely to be affected by the outcome of a particular 

matter with regard to a specific party such as a Department of Energy (DOE) or Atomic 

Weapons Employer (AWE) facility, such that s/he should be prohibited from 

participating personally and substantially in an official capacity in that particular matter 

concerning that party.

B. Potential Appearance of Loss of Impartiality

With regard to a potential appearance of loss of impartiality, the reviewing parties must 

determine if a particular matter involving specific parties is likely to have a direct and 

predictable effect on the financial interest of a member of the Board member’s

household, or if the Advisory Board member has a covered relationship with a specific 

person or entity who is a party (or represents a party) to a particular matter, such that 

the SGE’s participation in his/her official capacity in that matter would cause a 

reasonable person with knowledge of the relevant facts to question the SGE’s 

impartiality, and that the Advisory Board member should therefore be prohibited from 

participating in his/her official capacity in a particular matter involving specific parties.

C. Potential Appearance of Bias

With regard to a potential appearance of bias, the reviewing parties must determine 

whether the potential appearance of bias could raise questions as to the integrity of the 

EEOICPA program and if the Advisory Board member should therefore be prohibited 

from participating in his/her official capacity in a particular matter involving specific 

parties.

3. Program Contractors

A. Financial Conflicts of Interest

With regard to potential or actual financial conflicts of interest, the contract officer’s 

technical representative, in consultation with the contracting company’s project 

manager (or other contractor designee), the agency contract officer, and agency and 

HHS officials (including the NIOSH AOB/COB Officer) must determine if the contractor 

employee has a disqualifying financial interest and whether that interest is likely to be 

affected by the outcome of a particular matter with regard to a specific party, such as a 

DOE or AWE facility, such that s/he should be prohibited from participating personally 

and substantially in an official capacity in that particular matter concerning that party.
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B. Potential Appearance of Loss of Impartiality

With regard to a potential appearance of loss of impartiality, the contract officer’s 

technical representative, in consultation with the contracting company’s project 

manager, or other contractor designee, the agency contract officer, and agency and HHS 

officials (including the NIOSH AOB/COB Officer) must determine if a particular matter 

involving specific parties is likely to have a direct and predictable effect on the financial 

interest of a member of the contractor employee’s household, or if the contractor 

employee in question has a covered relationship with a specific person or entity who is a 

party (or represents a party) to a particular matter, such that the employee’s 

participation in his/her official capacity in that matter would cause a reasonable person 

with knowledge of the facts to question the employee’s impartiality, and that the 

employee should therefore be prohibited from participating in his/her official capacity 

in a particular matter involving specific parties.

C. Potential Appearance of Bias

With regard to a potential appearance of bias, the contract officer’s technical 

representative, in consultation with the contracting company’s project manager, or 

other contractor designee, the agency contract officer, and agency and HHS officials 

(including the NIOSH AOB/COB Officer) must determine whether the potential 

appearance of bias could raise questions as to the integrity of the EEOICPA program and 

if the contractor employee should therefore be prohibited from participating in his/her 

official capacity in a particular matter involving specific parties.

B. Requests for Remedies

This section describes (where a conflict or bias is found to be present) who may submit a request 

for a remedy to allow the affected individual to participate in a particular matter; the proper 

content of such a request; and to whom such requests are submitted.

1. NIOSH Employees

A. Financial Conflicts of Interest

When the reviewing parties determine that a financial conflict of interest exists, and the 

DCAS Director (or his/her designee) believes that there is a need for the conflicted 

employee’s participation in a particular matter of general applicability where such 

participation would otherwise be barred due to that conflict, the DCAS Director or 

designee may submit a written request for a waiver to the Designated Agency Ethics 

Official (DAEO)11. The request shall describe in detail both the circumstances 

surrounding the financial conflict and the reasons why the need for the employee’s 

participation in the particular matter of general applicability outweighs the possibility of 

the conflict adversely affecting the integrity of the employee’s services in that matter.

B. Potential Appearance of Loss of Impartiality

When the reviewing parties determine that a potential appearance of loss of 

impartiality concern exists, and the DCAS Director or designee believes that there is a 

need for the conflicted employee’s participation in a particular matter where such 

participation could otherwise be barred due to the employee’s covered relationship 

with a specific party to that particular matter, the DCAS Director or designee may 

 11 Currently, the DAEO is Ed Swindell, Associate General Counsel in the Ethics Division of OGC.
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submit a written request for an authorization to the NIOSH Director. If the NIOSH 

Director believes the request should go forward, he shall submit the request to the CDC 

Ethics office, which will forward the request to the CDC Deputy Ethics Counselor (DEC)12.

The request shall describe in detail both the specific circumstances surrounding the 

potential appearance of loss of impartiality and the reasons why the need for the 

conflicted employee’s participation in the particular matter outweighs the possibility 

that a reasonable person with knowledge of the relevant facts could question the 

employee’s impartiality in this situation as a result.13

C. Potential Appearance of Bias

When the reviewing parties determine that a potential appearance of bias concern 

exists, and the DCAS Director or designee believes there is a need for the conflicted 

employee’s participation in a particular matter involving specific parties where such 

participation might otherwise be barred due to the apparent bias, the DCAS Director or 

designee may submit a written request for an approval to the NIOSH AOB/COB Officer. 

The request shall describe in detail both the specific circumstances surrounding the 

potential appearance of bias and the reasons why the need for the conflicted 

employee’s participation in the particular matter outweighs the concern that the 

program’s integrity may be questioned as a result. 14

2. Advisory Board

A. Financial Conflicts of Interest

When the reviewing parties determine that a financial conflict of interest exists, and the 

DFO (or his/her designee) believes there is a need for the conflicted Board member’s 

participation in a particular matter of general applicability where such participation 

would otherwise be barred, the DFO or designee shall submit a written request for a 

waiver to the CDC MASO Director15. The request shall describe in detail both the 

circumstances surrounding the financial conflict and the reasons why the need for the 

Board member’s participation in the particular matter of general applicability outweighs 

the possibility for the conflict to adversely affect the integrity of the Board member’s 

services in the matter as a result.

B. Potential Appearance of Loss of Impartiality

When the reviewing parties determine that a potential appearance of loss of 

impartiality concern exists, and the DFO or designee believes there is a need for the 

conflicted Board member’s participation in the particular matter in question where such 

participation could otherwise be barred due to the Board member’s covered 

relationship with a specific party to that particular matter, the DFO or designee shall 

submit a written request for an authorization to the CDC MASO Director. The request 

shall describe in detail both the specific circumstances surrounding the potential 

appearance of loss of impartiality concern and the reasons why the need for the Board’s 

member’s participation in the particular matter outweighs the concern that a 

 12 Currently, the DEC is Carlton Duncan. 13 Specifically, the request should address the six balancing-test factors listed in section C.1.B below. 14 Specifically, the request should address the six balancing-test factors listed in section C.1.B below. 15 Currently, the CDC MASO Director is Elaine Baker.
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reasonable person with knowledge of the facts could question the integrity of the 

agency’s programs and operations as a result. 16

C. Potential Appearance of Bias

When the reviewing parties determine that a potential appearance of bias concern 

exists, the DFO or designee shall transmit this determination to the Board member in a 

guidance letter. If the DFO or designee and the Board member believe there is a need 

for the conflicted Board member to participate in the particular matter in question 

where such participation could otherwise be barred, the Board member shall submit a 

written request for an approval to the DFO or designee. The request shall describe in 

detail both the specific circumstances surrounding the potential appearance of bias 

concern and the reasons why the need for the Board member’s participation in the 

particular matter in question outweighs the concern that the program’s integrity may be 

questioned as a result.17

3. Program Contractors

A. Financial Conflicts of Interest

When the reviewing parties determine that a financial conflict of interest exists, and the 

contracting company’s project manager (or his/her designee) to that employee’s 

company believes that there is a need for the conflicted employee’s participation in a 

particular matter of general applicability where such participation would otherwise be 

barred due to that conflict, the project manager or designee may submit a written 

request for a waiver to the COTR. The request shall describe in detail both the 

circumstances surrounding the financial conflict and the reasons why the need for the 

employee’s participation in the particular matter of general applicability outweighs the 

possibility of the conflict adversely affecting the integrity of the employee’s services in 

that matter.

B. Potential Appearance of Loss of Impartiality

When the reviewing parties determine that a potential appearance of loss of 

impartiality concern exists, and the contracting company’s project manager (or his/her 

designee) to that employee’s company believes there is a need for the conflicted 

employee’s participation in the particular matter in question where such participation 

could otherwise be barred, the project manager or designee may submit a written 

request for an authorization to the COTR. The request shall describe in detail both the 

specific circumstances surrounding the potential appearance of loss of impartiality 

concern and the reasons why the need for the conflicted employee’s participation in the 

particular matter in question outweighs the concern that the program’s integrity may be 

questioned as a result. 18

C. Potential Appearance of Bias

When the reviewing parties determine that a potential appearance of bias concern 

exists, and the contracting company’s project manager or designee believes there is a 

need for that employee’s participation in a particular matter where such participation 

 16 Specifically, the request should address the six balancing-test factors listed in section C.1.B below. 17 Specifically, the request should address the six balancing-test factors listed in section C.1.B below. 18 Specifically, the request should address the six balancing-test factors listed in section C.1.B below.
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could otherwise be barred, the project manager or designee may submit a written 

request for an approval to the COTR. The request shall describe in detail both the 

specific circumstances surrounding the potential appearance of bias concern and the 

reasons why the need for the conflicted employee’s participation in the particular 

matter in question outweighs the concern that the program’s integrity may be 

questioned as a result. 19

C. Remedies – Availability, and Factors Considered in Their Application

This section describes to what extent a remedy may be available, and which factors are to be 

considered by the party that would grant the requested remedy.

1. NIOSH Employees

A. Financial Conflicts of Interest

When a financial conflict of interest is found to exist, the conflicted employee is 

prohibited from participating in a particular matter that is likely to have a direct and 

predictable effect on that financial interest, and cannot participate in that particular 

matter until and unless s/he is issued a waiver in writing to do so. A waiver is not 

considered until the employee first advises the deciding parties of the nature and 

circumstances of the particular matter, and makes full disclosure of the conflicted 

financial interest. A waiver may then be issued only if it is determined by the DAEO that 

the disqualifying financial interest in a particular matter or matters is not so substantial 

as to be deemed likely to affect the integrity of the employee’s services to the 

Government. While a limited waiver may be issued to allow participation in particular 

matters of general applicability where a specific financial conflict exists, a waiver will not

be issued to participate in a specific party-related matter that is the source of the 

conflict. It should be noted that waivers are rarely granted for employees under any 

circumstances.

B. Appearance of Loss of Impartiality

When an employee is determined to have an appearance of loss of impartiality concern 

regarding a particular matter involving specific parties, the employee may not 

participate in that matter until and unless s/he receives an authorization from his/her 

agency to do so. At that point, an analysis and determination is made, in light of all 

relevant circumstances, as to whether the interest of the government in the employee’s 

participation in the matter outweighs the concern that a reasonable person may 

question the integrity of the agency’s programs and operations. 

Factors that may be considered by the decision makers include:

(i) the nature of the relationship involved; 

(ii) the effect that resolving the matter would have upon the employee’s financial 

interests; 

(iii) the nature and importance of the employee’s role in the matter, including the 

extent to which the employee is called upon to exercise discretion in the matter;

(iv) the sensitivity of the matter; 

(v) the difficulty in reassigning the matter to another employee; and 

 19 Specifically, the request should address the six balancing-test factors listed in section C.1.B below.
12

(vi) adjustments that may be made to the employee’s duties to reduce or eliminate 

the likelihood that a reasonable person would question the employee’s 

impartiality.

C. Appearance of Bias

When it is determined that an employee’s participation in a particular matter involving 

specific parties would give rise to an appearance of bias concern, the employee may not 

participate in that matter until s/he has first requested, and received, an approval to so 

participate. An approval may be granted when it is determined, based on all relevant 

circumstances, that the interest of the government in the employee’s participation 

outweighs the concern that the program’s integrity may be questioned.

2. Advisory Board

A. Financial Conflicts of Interest

When a financial conflict of interest is found to exist, the conflicted Board member is 

prohibited from participating in a particular matter that is likely to have a direct and 

predictable effect on that financial interest, and cannot participate in that particular 

matter until and unless s/he is issued a waiver in writing to do so. A waiver will not be 

considered until the Board member first advises the deciding parties of the nature and 

circumstances of the particular matter, and makes full disclosure of the conflicted 

financial interest (via his/her financial disclosure report, and other information as 

necessary). The agency’s determination must be based on a certification that the need 

for the Board member’s services outweighs the potential for a conflict of interest 

created by the financial interest involved. While a limited waiver may be issued to allow 

participation in particular matters of general applicability where a specific financial 

conflict exists, a waiver will not be issued to participate in a specific party-related matter 

that is the source of the conflict. 20

B. Appearance of Loss of Impartiality

When an Advisory Board member is determined to have an appearance of loss of 

impartiality concern regarding a particular matter involving specific parties, that Board 

member may not participate in that matter until and unless s/he receives an 

authorization from his/her agency to do so. At that point, an analysis and determination 

is made, in light of all relevant circumstances, as to whether the interest of the 

government in the Board member’s participation in the matter outweighs the concern 

that a reasonable person may question the integrity of the agency’s programs and 

operations. 

Factors that may be considered include: 

 20 In certain circumstances involving more broadly applicable issues, a Board member may also be eligible for a 

regulatory exemption. OGE regulation 5 C.F.R. § 2640.203(g) permits an SGE such as a Board member to 

participate “in any particular matter of general applicability where the disqualifying financial interest arises from 

his non-Federal employment or non-Federal respective employment, provided that the matter will not have a 

special or distinct effect on the employee or employer other than as part of a class.” A determination of whether 

this exemption is applicable, and whether it should be granted to the Board member in question, is to be made by 

the same parties that determine remedies for Board members in other instances.
13

(i) the nature of the relationship involved;

(ii) the effect that resolving the matter would have upon the Board member’s 

financial interests; 

(iii) the nature and importance of the Board member’s role in the matter, including 

the extent to which the Board member is called upon to exercise discretion in 

the matter; 

(iv) the sensitivity of the matter; 

(v) the difficulty in reassigning the matter to another Board member; and

(vi) adjustments that may be made to the Board member’s duties to reduce or 

eliminate the likelihood that a reasonable person would question the Board 

member’s impartiality.

C. Appearance of Bias

Where an Advisory Board member’s participation in a particular matter involving 

specific parties is determined to present an appearance of bias concern, that Board 

member may not participate in that matter until s/he has first requested, and received, 

an approval to so participate. An approval may be granted when it is determined, based 

on all relevant circumstances, that the interest of the government in the Board 

member’s participation outweighs the concern that the program’s integrity may be 

questioned.

3. Program Contractors

A. Financial Conflicts of Interest

When a financial conflict of interest is found to exist, the conflicted contractor employee 

is prohibited from participating in a particular matter that is likely to have a direct and 

predictable effect on that financial interest, and cannot participate in that particular 

matter until and unless s/he is issued a waiver in writing to do so. A waiver is not 

considered until the employee first advises the deciding parties of the nature and 

circumstances of the particular matter, and makes full disclosure of the conflicted 

financial interest. A waiver may then be issued only if it is determined that the 

disqualifying financial interest in a particular matter or matters is not so substantial as to 

be deemed likely to affect the integrity of the employee’s services to the Government. 

While a limited waiver may be issued to allow participation in particular matters of 

general applicability where a specific financial conflict exists, a waiver will not be issued 

to participate in a specific party-related matter that is the source of the conflict. It 

should be noted that waivers are rarely granted for contractor employees under any 

circumstances.

B. Appearance of Loss of Impartiality

When a contractor employee is determined to have an appearance of loss of 

impartiality concern, that employee may not participate in a particular matter involving 

specific parties unless s/he first obtains an authorization in writing to do so. At that 

point, an analysis and determination is made, in light of all relevant circumstances, as to 

whether the interest of the government in the employee’s participation outweighs the 

concern that the program’s integrity could be questioned as a result.

Factors that may be considered include: 
14

(i) the nature of the relationship involved;

(ii) the effect that resolving the matter would have upon the employee’s 

financial interests; 

(iii) the nature and importance of the employee’s role in the matter, 

including the extent to which the employee is called upon to exercise 

discretion in the matter; 

(iv) the sensitivity of the matter; 

(v) the difficulty in reassigning the matter to another employee; and

(vi) adjustments that may be made to the employee’s duties to reduce or 

eliminate the likelihood that a reasonable person would question the 

employee’s impartiality.

C. Appearance of Bias

When it is determined that a contractor employee’s participation in a particular matter 

involving specific parties (such as a DOE or AWE facility) would give rise to an 

appearance of bias concern, that individual may not participate in that matter without 

first obtaining an approval. Such an approval may be granted when it is determined, 

based on all relevant circumstances, that the interest of the government in the 

employee’s participation outweighs the concern that the program’s integrity may be 

questioned as a result.

D. Remedies continued – Granting and Issuance

This section describes which individuals may grant a remedy, and the circumstances attendant to 

the remedy’s granting.

1. NIOSH Employees

A. Financial Conflicts of Interest

In instances involving financial conflicts of interest, waivers may only be issued by the

DAEO, in consultation with the Ethics Division of the HHS Office of the General Counsel 

and attorneys in the Public Health Division of OGC. Waivers must be granted in writing, 

do not cover past conduct, and are only provided on a very limited, case-by-case basis at 

the discretion of the agency, based on the specific circumstances of the matter in 

question. 

B. Appearance of Loss of Impartiality

In instances involving appearances of loss of impartiality, authorizations may be granted 

by the DEC, in consultation with attorneys in the Ethics and Public Health Divisions of 

OGC. Authorizations must be in writing and are granted on a case-by-case basis at the 

discretion of HHS, based on the specific circumstances of the matter in question.

C. Appearance of Bias

In instances involving appearances of bias, approvals may be granted by the 

NIOSHAOB/COB Officer, in consultation with attorneys in the Ethics and Public Health 

Divisions of OGC. Approvals must be granted in writing, and are provided on a case-bycase basis, based on the specific circumstances of the matter in question.
15

2. Advisory Board

A. Financial Conflicts of Interest

Where a financial conflict of interest is determined to exist, a waiver may be issued by 

the CDC MASO Director, in consultation with both the DFO and attorneys in the Ethics 

and Public Health Divisions of OGC. Waivers must be issued in writing, do not cover past 

conduct, and are granted only on a limited, case-by-case basis, at the discretion of the 

agency, based on the specific circumstances of the matter in question.

B. Appearance of Loss of Impartiality

In instances involving appearances of loss of impartiality, authorizations may be granted 

by the CDC MASO Director, in consultation with both the DFO and attorneys in the 

Ethics and Public Health Divisions of OGC. Authorizations must be made in writing, and 

are granted on a case-by-case basis at the discretion of HHS, based on the specific 

circumstances of the matter in question.

C. Appearance of Bias

In instances involving appearances of bias, approvals may be granted by the DFO, in 

consultation with the CDC Committee Management Officer and attorneys in the Ethics 

and Public Health Divisions of OGC. Approvals must be made in writing, and are granted 

on a case-by-case basis at the discretion of the agency, based on the specific 

circumstances of the matter in question. 

3. Program Contractors

A. Financial Conflicts of Interest

In instances where a contractor employee is determined to have a financial conflict of 

interest, the employee must first obtain a waiver before participating in a particular 

matter of general applicability. A waiver is issued by the agency21 after a determination 

by the contract officer’s technical representative, in consultation with the contract 

project manager, the agency contract officer, and agency and HHS officials (including 

the NIOSH AOB/COB Officer), that the interest of the government in the contractor 

employee’s participation in the matter outweighs the concern that the program’s 

integrity may be questioned. Waivers must be issued in writing, do not cover past 

conduct, and are granted only on a limited, case-by-case basis, at the discretion of the 

agency, based on the specific circumstances of the matter in question.

B. Appearance of Loss of Impartiality

In instances where it is determined that circumstances would cause a reasonable person 

with knowledge of the relevant facts to question a contractor employee’s impartiality 

regarding specific party matters, the employee must first obtain an authorization before 

participating in that particular matter involving specific parties. An authorization is 

issued by the agency22 after a determination by the contract officer’s technical 

representative, in consultation with the contract project manager, the agency contract 

officer, and agency and HHS officials (including the NIOSH AOB/COB Officer), that the 

interest of the government in the contractor employee’s participation in the matter 

 21 The waiver must be signed by both the COTR or designee, and the NIOSH AOB/COB Officer. 22 The authorization must be signed by both the COTR or designee, and the NIOSH AOB/COB Officer.
16

outweighs the concern that the program’s integrity may be questioned. An 

authorization is issued in writing, on a case-by-case basis, at the discretion of the 

agency, based on the specific circumstances of the matter in question.

C. Appearance of Bias

In instances where it is determined that a contractor employee’s participation in a 

particular matter involving specific parties would give rise to an appearance of bias, the 

employee must first obtain an approval before participating in that particular matter 

involving specific parties. An approval is issued by the agency23 after a determination by 

the contract officer’s technical representative, in consultation with the contract project 

manager, the agency contract officer, and agency and HHS officials (including the NIOSH 

AOB/COB Officer), that the interest of the government in the contractor employee’s 

participation in the matter outweighs the concern that the program’s integrity may be 

questioned. An approval is issued in writing, on a case-by-case basis, at the discretion of 

the agency, based on the specific circumstances of the matter in question.

V. Key Program Functions and Program Support Functions

This section describes a number of Program functions integral to the EEOICPA Program, as well as 

which such functions may be performed by conflicted individuals with remedial documentation.

A. Key Program Functions

Key Program Functions (KPFs) include, but are not limited to, those activities integral to the 

EEOICPA Program that must be performed by individuals who do not have a financial conflict of 

interest, appearance of loss of impartiality concern, or appearance of bias concern (as those 

terms are defined in the NIOSH AOB Policy and its Implementing Procedures), with regard to the 

site(s) that are the subject of the key Program function(s). Accordingly, except as specified 

immediately below, a NIOSH employee or Program contractor employee may not perform any 

key Program function(s) for the site(s) where s/he is conflicted.

In the case of a Site Expert, whose value to the Program is inherently derived from his/her 

service at specific sites, his/her services may be utilized, subject to the following conditions: Not 

only does s/he require remedial documentation to provide controlled and attributed input of 

any type to a key Program function document or process, but the site expert’s permitted duties 

must also be carefully delineated in advance of his/her participation, and that input, and any 

attendant conflicts, must be clearly attributed to the site expert wherever it appears in the 

subject document, and documented elsewhere as appropriate (for instance, by preserving 

formal notes of an interview with a site expert in the document record).

Similarly, a Scientific/Technical Peer Reviewer is permitted, subject to first receiving the 

appropriate remedial documentation, to conduct such reviews of key Program function 

documents concerning specific sites at which that reviewer may be conflicted.

Key Program functions have been determined to include the following (please see Appendix A 

for a more complete description of these functions):

 23 The approval must be signed by both the COTR or designee, and the NIOSH AOB/COB Officer.
17

1. Document Approval Authority

2. NIOSH AOB/COB Officer

3. Site Profile Document Owner

4. Site-Specific Technical Information Bulletin (TIB) Owner

5. SEC Petition Evaluation Report Owner

6. Case Manager

7. Dose Reconstructor

8. Dose Reconstruction Reviewer

9. Dose Reconstruction Report Peer Reviewer

10. Worker/Site Profile Reviewer

11. Lead Worker/Site Profile Reviewer

12. SEC Petition Reviewer

13. Lead SEC Petition Reviewer

14. Scientific/Technical Peer Reviewer

15. Author/owner of site-specific “white paper” or other product prepared for purposes of 

Board, Subcommittee, or Working Group discussion

16. Site Expert

B. Program Support Functions

Program Support Functions (PSFs) are those functions that are not tied to a specific site or sites 

and therefore are considered to involve particular matters of general applicability that present 

little or no risk of conflict of interest, or appearance of loss of impartiality or of bias, with regard 

to a conflicted individual. Accordingly, otherwise-conflicted individuals may generally perform 

these functions without having to obtain remedial documentation. PSFs include, but are not 

limited to, the following, as listed below (see Appendix A for complete descriptions):

1. Implementation Guide/General Guidance (IG/GG) Document Owner

2. Multiple-Site Technical Information Bulletin Owner

3. Subject Expert/Technical Specialist

VI. Declaring Conflicts/Biases

This section describes how the existence of individuals’ conflicts and biases, as well as any remedial 

documentation subsequently issued to those persons, is to be communicated to Program stakeholders, 

members of the public, and other interested parties.

Methods of Declaring Conflicts/Biases

1. Websites

A. NIOSH Employees

1. Financial Conflicts of Interest

In instances where a NIOSH employee is determined to have a financial conflict of 

interest with regard to a specific DOE or AWE facility and/or subject matter, a list of 

the sites and/or subject matters with which s/he is so conflicted shall be posted on 

the NIOSH/DCAS website, by employee name. A list of any waivers issued to that 

employee to allow him/her to work on matters involving an otherwise conflicted 

site or subject matter will also be posted.
18

2. Appearance of Loss of Impartiality

In instances where a NIOSH employee is determined to have an appearance of loss 

of impartiality concern with regard to a specific DOE or AWE facility and/or subject 

matter, a list of the sites and/or subject matters with which s/he is so conflicted 

shall be posted on the NIOSH/DCAS website, by employee name. A list of any 

authorizations issued to that employee to allow him/her to work on matters 

involving an otherwise conflicted site or subject matter shall also be posted.

3. Appearance of Bias

In instances where a NIOSH employee is determined to have an appearance of bias 

concern with regard to a specific DOE or AWE facility and/or subject matter, a list of 

the sites and/or subject matters with which s/he is so conflicted shall be posted on 

the NIOSH/DCAS website, by employee name. A list of any approvals issued to that 

employee to allow him/her to work on matters involving an otherwise conflicted 

site or subject matter shall also be posted.

B. Advisory Board

1. Financial Conflicts of Interest

In instances when an Advisory Board member has been determined to have a 

financial conflict involving a specific DOE or AWE facility and/or subject matter, a list 

of the sites and/or subject matters with which the Board member is conflicted shall 

be included in the Board member’s “Conflict of Interest Disclosure Statement,” 

which shall be posted on the NIOSH/DCAS website by Board member name. A list of 

the waivers granted to the Board member to permit his/her participation in 

otherwise conflicted matters shall also be posted.

2. Appearance of Loss of Impartiality

In instances when an Advisory Board member has been determined to have an 

appearance of loss of impartiality concern with regard to a specific DOE or AWE 

facility and/or subject matter, a list of the sites and/or subject matters with which 

the Board member is conflicted shall be included in the Board member’s “Conflict of 

Interest Disclosure Statement,” which shall be posted on the NIOSH/DCAS website 

by Board member name. A list of the authorizations granted to the Board member 

to permit his/her participation in otherwise conflicted matters shall also be posted.

3. Appearance of Bias

In instances when an Advisory Board member has been determined to have an 

appearance of bias concern with regard to a specific DOE or AWE facility and/or 

subject matter, a list of the sites and/or subject matters with which the Board 

member is conflicted shall be included in the Board member’s “Conflict of Interest 

Disclosure Statement,” which shall be posted on the NIOSH/DCAS website by Board 

member name. A list of the approvals granted to the Board member to permit 

his/her participation in otherwise conflicted matters shall also be posted.
19

C. Program Contractors

1. Financial Conflicts of Interest

In instances where a contractor employee is determined to have a financial conflict 

of interest with regard to a specific DOE or AWE facility and/or subject matter, that 

information shall be posted on the contractor’s homepage in the employee’s 

conflict-of-interest disclosure statement, retrievable by employee name. This 

statement shall also contain a list of all waivers granted to the employee to permit 

his/her participation in otherwise conflicted matters. Links to all such program 

contractor disclosure statements shall be provided on the NIOSH/DCAS website.

2. Appearance of Loss of Impartiality

In instances where a contractor employee is determined to have an appearance of 

loss of impartiality concern with regard to a specific DOE or AWE facility and/or 

subject matter, that information shall be posted on the contractor’s homepage in 

the employee’s conflict-of-interest disclosure statement, retrievable by employee 

name. This statement shall also contain a list of all authorizations granted to the 

employee to permit his/her participation in otherwise conflicted matters. Links to all 

such program contractor disclosure statements shall be provided on the 

NIOSH/DCAS website.

3. Appearance of Bias

In instances where a contractor employee is determined to have an appearance of 

bias concern with regard to a specific DOE or AWE facility and/or subject matter, 

that information shall be posted on the contractor’s homepage in the employee’s 

conflict-of-interest disclosure statement, retrievable by employee name. This 

statement shall also contain a list of all approvals granted to the employee to permit 

his/her participation in otherwise conflicted matters. Links to all such program 

contractor disclosure statements shall be provided on the NIOSH/DCAS website.

2. Public Meetings

A. NIOSH Employees

1. Financial Conflicts of Interest

In instances where a NIOSH employee is determined to have a financial conflict of 

interest, s/he should not attend any (or any portion of the) public meeting where 

that conflict may be pertinent, or must leave the discussion and proceed to the back 

of the meeting room when the employee becomes aware that the meeting will be 

addressing the matter that poses the conflict. If the employee has a waiver that will 

allow him/her to be present at the meeting, the employee shall announce both 

his/her conflict and the waiver prior to speaking for the first time at the meeting, or 

when asked by the DFO during a full Board or Board working group meeting. 

2. Appearance of Loss of Impartiality

In instances where a NIOSH employee is determined to have an appearance of loss 

of impartiality concern, s/he should not attend any (or any portion of the) public 

meeting where that conflict may be pertinent, or must leave the discussion and 

proceed to the back of the meeting room when the employee becomes aware that 
20

the meeting will be addressing the matter that poses the conflict. If the employee 

has an authorization that will allow him/her to be present at the meeting, the 

employee shall announce both his/her conflict and the authorization prior to 

speaking for the first time at the meeting, or when asked by the DFO during a full 

Board or Board working group meeting. 

3. Appearance of Bias

In instances where a NIOSH employee is determined to have an appearance of bias 

concern, s/he should not attend any (or any portion of the) public meeting where

that conflict may be pertinent, or must leave the discussion and proceed to the back 

of the meeting room when the employee becomes aware that the meeting will be 

addressing the matter that poses the conflict. If the employee has an approval that 

will allow him/her to be present at the meeting, the employee shall announce both 

his/her conflict and the approval prior to speaking for the first time at the meeting, 

or when asked by the DFO during a full Board or Board working group meeting. 

B. Advisory Board

1. Financial Conflicts of Interest

In instances where an Advisory Board member is determined to have a financial 

conflict of interest, s/he should not attend any (or any portion of the) public 

meeting where that conflict may be pertinent, or should leave the discussion and 

proceed to the back of the meeting room when the Board member becomes aware 

that the meeting will be addressing the matter that poses the conflict. If the Board 

member has a waiver that will allow him/her to be present at the meeting, the 

Board member shall announce both his/her conflict and the waiver prior to speaking 

for the first time at the meeting, or when asked by the DFO during a full Board or 

Board working group meeting.24

2. Appearance of Loss of Impartiality

In instances where an Advisory Board member is determined to have an appearance 

of loss of impartiality concern, s/he should not attend any (or any portion of the) 

public meeting where that conflict may be pertinent, or should leave the discussion 

and proceed to the back of the meeting room when the Board member becomes 

aware that the meeting will be addressing the matter that poses the conflict. If the 

Board member has an authorization that will allow him/her to be present at the 

meeting, the Board member shall announce both his/her conflict and the 

authorization prior to speaking for the first time at the meeting, or when asked by 

the DFO during a full Board or Board working group meeting. 

3. Appearance of Bias

In instances where an Advisory Board member is determined to have an appearance 

of bias concern, s/he should not attend any (or any portion of the) public meeting 

where that conflict may be pertinent, or should leave the discussion and proceed to 

the back of the meeting room when the Board member becomes aware that the 

 24 In such instances, the DFO may announce the Advisory Board member’s recusal. Generally, the affected Advisory 

Board member (absent a waiver) may not be present at the meeting if the discussion will solely cover those 

sites/matters for which the member is conflicted.
21

meeting will be addressing the matter that poses the conflict. If the Board member 

has an approval that will allow him/her to be present at the meeting, the Board 

member shall announce both his/her conflict and the approval prior to speaking for 

the first time at the meeting, or when asked by the DFO during a full Board or Board 

working group meeting. 

C. Program Contractors

1. Financial Conflicts of Interest

In instances where a contractor employee is determined to have a financial conflict 

of interest, that employee should not attend any (or any portion of the) public 

meeting where that conflict may be pertinent, or must leave the discussion and 

proceed to the back of the meeting room when the employee becomes aware that 

the meeting will be addressing the matter that poses the conflict. If the employee 

has a waiver that will allow him/her to be present at the meeting, the employee 

shall announce both his/her conflict and the waiver prior to speaking for the first 

time at the meeting, or when asked by the DFO during a full Board or Board working 

group meeting.

2. Appearance of Loss of Impartiality

In instances where a contractor employee is determined to have an appearance of 

loss of impartiality concern, that employee should not attend any (or any portion of 

the) public meeting where that conflict may be pertinent, or must leave the 

discussion and proceed to the back of the meeting room when the employee 

becomes aware that the meeting will be addressing the matter that poses the 

conflict. If the employee has been granted an authorization that will allow him/her 

to be present at the meeting in question, the employee shall announce both his/her 

conflict, and the authorization, prior to speaking for the first time at the meeting, or 

when asked by the DFO during a full Board or Board working group meeting. 

3. Appearance of Bias

In instances where a contractor employee is determined to have an appearance of 

bias concern, that employee should not attend any (or any portion of the) public 

meeting where that conflict may be pertinent, or must leave the discussion and 

proceed to the back of the meeting room when the employee becomes aware that 

the meeting will be addressing the matter that poses the conflict. If the employee 

has been granted an approval that will allow him/her to be present at the meeting 

in question, the employee shall announce both his/her conflict, and the approval, 

prior to speaking for the first time at the meeting, or when asked by the DFO during

a full Board or Board working group meeting. 

Appendices:

A. Descriptions of Key Program Functions and Program Support Functions

B. NIOSH Policy on the Appearance of Bias for the EEOICPA Program and General Conflict of 

Interest Requirements

C. 18 U.S.C. § 208

D. 5 C.F.R. § 2635.502

E. NIOSH AOB Disclosure Form